“What farmers need is a meaningful scheme which pays a base payment of €10,000. Payments based on results would be on top of this.
“In their more productive fields, the farmer should be able to concentrate their environmental measure on the boundary/margin areas to allow them to farm productively. The field measures should be carried out on their more marginal land. Any new pilot scheme should include the rejuvenation of old pastures. Any rock outcrop, marsh/pond area or areas that were excluded before in the Basic Payment Scheme (BPS) should be included under new scheme as areas of biodiversity.”
“It is essential to maximise participant eligibility and make the scheme as accessible as possible. Derogation farms and commercial farms should be the focus given the fact that GLAS was largely inaccessible for this category of farmer.
“Any measure undertaken should not impact the eligibility of land for nitrates derogation and direct payment entitlements, and measures should not have a negative impact on the productivity of the farm if this scheme is to be adopted by commercial farming.”
Some of the actions that ICMSA believes would be accessible to the commercial farmer include:
“The reference to ‘target lands’ in the public consultation document is unacceptable to the INHFA.
“Selecting lands with only “potential for environmental improvement” is totally unacceptable and discriminates against farmers who are already delivering for the environment.
“There needs to be a basic entry requirement. This baseline should require all farmers to not exceed the nitrates threshold of 170kg/ha on the date of application. In all previous agri-environmental schemes farmers with Natura and commonage lands got priority access and this must follow here.”
“ICSA proposes that farmers are paid a basic entry cost of €2,000/ annum to cover time spent planning and strategising REPS participation. Farmers would have an option of choosing a minimum of three modules and a maximum of five; base rate of €3,200 with an €1,000 top-up linked to biodiversity and environment.
“There is a clear need that no farmer should be excluded based on their enterprise or stocking rate from accessing the scheme. In addition, schemes must be tailored to suit different enterprise types and intensities.”
Potential measures would include:
An Taisce said any pilot initiative needs to “address the May 2020 EU Court of Auditors report on the EU-wide failure of successive agri-environmental schemes under CAP to reverse biodiversity loss”. It said it must ensure the practical application of the 2019 European Green Deal and the actions and targets set out in the Farm to Fork and Biodiversity strategies. It said the scheme must “promote diversification from ruminant animal agriculture”.